S. 15(2.12) or s. 212.3(12) allows for a late filing of a PLOI election by up to three years provided that the late filing penalties are paid by the corporation resident in Canada (CRIC).
CRA indicated that it has revised its procedures for the late-filing of a PLOI election. Although this can still be accomplished by the CRIC filing an amended Schedule 1, the CRIC can instead use recently published CRA forms (Forms T1521 and T2311 for filings under s. 15(2.11) and s. 212.3(11), respectively) to provide the relevant information.
Regarding loan indebtedness owing to a qualified Canadian partnership, the instructions contained in Part 3 of Form T1521 will be revised to clarify that, in order to process the adjustment in respect of the qualified Canadian partnership and corporate partners, the taxpayer should submit an amended partnership information return(s) as well as an amended Schedule 1.